What is a FAA DER?
What is the difference between TSO and PMA?
What is the difference between STC and TC?
Why involve a DER for TSO Projects?
What is a Management DER?
What is a DAR?
When is a DAR needed?
Can FAA DERs support foreign projects?
What is a BiLateral Aviation Safety Agreement?
What is an issue paper?
What is the difference between RTCA DO-227 and RTCA DO-311?
Test Sample Information

What is a FAA DER?

Title 49 of the United States Code 44702(d) empowers the Administrator to “…delegate a qualified private person, or to an employee under the supervision of that person, a matter related to the examination, testing, and inspection necessary to issue a certificate, and issuing the certificate.” Title 14 of the Code of Federal Regulations (14 CFR) part 183, Representatives of the Administrator, prescribes the requirements for designating private persons to act as representatives of the Administrator for the purpose of issuing airmen and aircraft certificates.
Part 183, subpart B, Certification of Representatives, empowers the FAA to select designees from qualified persons who apply by letter accompanied by a statement of qualifications. The delegations are limited in scope in that all requirements, policy, direction, and interpretations must reside with the Administrator.
Section 183.29, Designated Engineering Representatives, defines the types of designated engineering representative (DER) appointments in the following technical disciplines:
(1) Structural engineering.
(2) Powerplant engineering.
(3) Systems and equipment engineering.
(4) Radio engineering.
(5) Engine engineering.
(6) Propeller engineering.
(7) Flight analyst.
(8) Flight test pilot (FTP).
(9) Acoustical engineering.
A designation is a privilege, not a right, and not every qualified applicant will be granted a designation.

What is the difference between TSO and PMA?


A Technical Standard Order (TSO) is a minimum performance standard for specified materials, parts, and appliances used on civil aircraft. When authorized to manufacture a material, part, or appliances to a TSO standard, this is referred to as TSO authorization. Receiving a TSO authorization is both design and production approval.

Receiving a TSO authorization is approval to manufacture an article that may be installed on an aircraft only after showing that the article meets the specific airworthiness requirements (certification basis) of a particular aircraft model. In other words, receiving a TSO authorization means that an article meets a minimum performance requirement independent of the article’s intended installation on an aircraft.
Receiving a TSO Authorization is not an approval to install and use the article in the aircraft. It means that the article meets the specific TSO and the applicant is authorized to manufacture it. It is up to the applicant to ensure the TSO’d article is appropriate for use on the aircraft and meets all of the installation and operational requirements set forth by the FAA. A separate FAA approval is required to install the article on an aircraft.
Approval of a TSO’d article for use on an aircraft is typically done via the STC or TC approval processes.


A Parts Manufacture Approval (PMA) is a combined design and production approval for modification and replacement articles. It allows a manufacturer to produce and sell these articles for installation on type certificated products. A PMA differs from a TSO in that the approval is valid only for the aircraft or aircraft model that the product is approved on. The design approval phase of PMA certifies that a replacement or modification article complies with the airworthiness standards of eligible products (aircraft, engine, or propeller). The applicant shows this compliance through tests and computations unless the article is identical to the article design on a type-certificated product. Identicality means that an article is the same in all respects to an article design in a type-certificated product. Evidence of license agreement shows this identicality. A PMA is typically done in conjunction with a STC or TC.

What is the difference between STC and TC?

A supplemental type certificate (STC) is a type certificate (TC) issued when an applicant has received FAA approval to modify an aircraft from its original design. The STC, which incorporates by reference the related TC, approves not only the modification but also how that modification affects the original design.
A type certificate (TC) is issued to a new aircraft type and can only be applied for and issued to the manufacturer of that aircraft. Amended Type Certificates (ATC) can be issued to the aircraft Manufacturer seeking to modify an existing aircraft.

Why involve a DER for TSO Projects?

Order 8110.37e effective 04/30/2011, removed the policy allowing the use of DERs for approving TSO data for TSOA applications. This means that DERs are no longer authorized to provide FAA form 8110.3 for data supporting a TSO. However, DER’s can be used as a technical consultant, i.e. an employee of, or contractor to applicant/holder, but not as an FAA designee. It has been our experience that the FAA encourages the use of DERs on TSO projects in a technical consultant capacity to ensure that the process is followed and the data packages to be submitted are adequate. This can result in a significant reduction in FAA approval time if the FAA knows that a DER is being consulted.

What is a Management DER?

Management DER. The management DER, usually a consultant DER, performs FAA certification project management duties for the FAA, acting like an FAA project manager.
They organize the applicant’s certification program, directing, overseeing, and managing the tasks of technical assessments and findings of compliance. The management DER ensures all technical data required to show compliance is reviewed and approved by the appropriate technical DER, except those items reserved by the FAA for approval. To establish his capability as an FAA project manager, we must first appoint a management DER under one of the delegations listed in § 183.29

What is a DAR?

A Designated Airworthiness Representative (DAR) is an individual appointed in accordance with 14 CFR � 183.33 who may perform examination, inspection, and testing services necessary to the issuance of certificates. There are two types of DARs, manufacturing and maintenance.

  • Manufacturing DARs must possess aeronautical knowledge, experience, and meet the qualification requirements of Order 8100.8.
  • Maintenance DARs must hold:
    • a mechanic’s certificate with an airframe and powerplant rating under 14 CFR part 65, Certification: Airmen Other Than Flight Crewmembers, or
    • a repairman certificate and be employed at a repair station certificated under 14 CFR part 145, or an air carrier operating certificate holder with an FAA-approved continuous airworthiness program, and must meet the qualification requirements of Order 8100.8, Chapter 14.

When is a DAR needed?

A manufacturing DAR is typically needed to perform manufacturing conformity inspections on articles supporting “for credit” functional or operational testing.

Manufacturing DARs are responsible for performing authorized functions in accordance with the pertinent regulations, FAA directives, and any specific instructions conveyed by their managing office(s). A DAR will—
(1) Perform only authorized functions within the limits of their authority.
(2) Contact their managing office for authorization BEFORE accepting any certification or inspection activity requested by an applicant. Obtain any special directions or instructions deemed necessary by the advisor requesting the inspection activity.
(3) Provide information relating to their accomplishments in accordance with the schedule established by their managing office.
(4) Ensure that FAA forms, certificates, and other official documents are properly safeguarded. Under no circumstance may any certificate be in the possession of an applicant until the DAR has completed and signed the certificate. All airworthiness certificates or approvals and related documents (for example, application for airworthiness certificates, limitations cited and attached to FAA Form 8130-7, Special Airworthiness Certificate, and FAA Form 8100-2, Standard Airworthiness Certificate) will indicate the DAR’s printed or typed name, signature, and designation number.
(5) Not perform any mechanical, maintenance, or inspection function on behalf of an applicant (for example, owner, agent, repair station, or production approval holder (PAH)) on products or articles for which an airworthiness certificate or approval is sought. This would not preclude the DARs from performing maintenance, mechanical functions, or inspections in a non-DAR capacity when NOT involved in the airworthiness certification/approval actions under their DAR authority.
(6) Ensure a product meets the FAA-approved type design data, is in a condition for safe operation, and complies with all applicable regulations (for example, marking requirements, registration, and special importing requirements) before issuing an airworthiness certificate.

The DARs will seek guidance from their managing office when problems arise that they cannot resolve.
(7) Ensure FAA Form 8100-1, Conformity Inspection Record, is used in accordance with the instructions provided in FAA Order 8130.2, Airworthiness Certification of Aircraft and
Related Products.
(8) Submit applicable original or duplicate documents within 7 days of completion to the managing office for review.
(9) Review applications for completeness and ensure the various airworthiness certificates or approvals have certification statements signed by an applicant or authorized agent.
When appropriate, the DAR also must obtain a completed FAA Form 8130-9, Statement of
Conformity, from an applicant before performing any inspections.
(10) Ensure special flight permits issued for overweight operations are in accordance with the latest revisions of all applicable guidance material (for example, FAA Order 8130.2).
The DAR will contact the managing office to obtain any special directions

Can FAA DERs support foreign projects?

DERs can support foreign CAA projects. In Support of Foreign Civil Aviation Authority (CAA) Requirements. A DER must provide the original Form 8110-3 and substantiating data to the project ACO for review and concurrence. The project ACO will transmit FAA approval to the foreign CAA.

What is a BiLateral Aviation Safety Agreement?

Bilateral Aviation Safety Agreement (BASA). Reference the current edition of Advisory Circular (AC) 21-23, Airworthiness Certification of Civil Aircraft, Engine, Propellers, and Related Products Imported to the United States.

A BASA is a government-to-government agreement, consisting of one Executive Agreement and one or more implementation procedures (IP), to facilitate the recognition of procedures for the reciprocal acceptance in technical areas that may include:

(a) Airworthiness approvals of civil aeronautical products.
(b) Environmental approvals and environmental testing.
(c) Approval and monitoring of maintenance facilities and alterations or modification facilities.
(d) Approval and monitoring of maintenance personnel.
(e) Approval and monitoring of crews.
(f) Approval and monitoring of flight operations.
(g) Approval and monitoring of aviation training establishments.

The term AA refers to the authority of a contracting State that has responsibility for the establishment, implementation, and oversight responsibilities of aviation regulation within their country.
These agreements are replacing Bilateral Airworthiness Agreements (BAA). BAA are also a government-to-government agreement, consisting of one Executive Agreement, normally dealing with specific areas of agreement but do not include IP.

What is an issue paper?

The Federal Aviation Administration (FAA), use issue papers when necessary to provide a structured means of accomplishing the necessary steps in the type certification and type validation processes. Type certification includes projects for type certificates, amended type certificates, type design changes, STCs and amended STCs. For FAA approvals such as 14 CFR § 21.305(d) approvals and PMA projects, they can be used, with discretion, in order to document and resolve compliance issues where directorate or policy office guidance is required.

Issue papers provide a structured means for describing and tracking the resolution of significant technical, regulatory, and administrative issues that occur during a project. The issue paper process establishes a formal communication for significant issues between you, the applicant, a foreign civil aviation authority (FCAA) if applicable, and the FAA.

For type certification projects, issue papers are useful tools for keeping an unbiased uniform certification approach between applicants. Issue papers also form a valuable reference for future type certification programs and for development of regulatory changes. By describing significant or precedent-setting technical decisions and the rationales employed, they are ideal source documents. For example, a certification summary report (if required by the accountable directorate) may be generated by extracting the final issue resolution from the issue papers (omitting any proprietary information).

For type validation programs, when the FAA is the validating authority (VA), the FAA uses issue papers mainly to address differences between FAA and the certificating authority (CA) airworthiness standards and interpretations. The FAA will also write issue papers on certification basis (G-1 Issue Paper) and other unique import requirements.

Types of Issue Papers:

Method of Compliance (MoC). The most common type of issue paper defines a particular method of compliance that requires directorate or policy office coordination as a result of peculiarities in the type design or the need to define specific conditions and/or establish the environment under which substantiation must be shown.

Equivalent Level of Safety (ELOS). Equivalent level of safety (ELOS) findings are granted when literal compliance with a certification regulation cannot be shown and compensating factors exist which can provide an ELOS (see 14 CFR § 21.21(b)(1)). Compensating factors are not exist or are inadequate. These issue papers are used to develop the basis, need, and wording of special conditions. A special condition contains only the airworthiness standards necessary to establish a level of safety equivalent to that established by the applicable regulations. Special conditions are unique to the specific certification program in which they are issued. The FAA has delegated authority for issuing them to the directorates, or to the Aircraft Engineering Division (AIR-100) for areas of responsibility not assigned to a directorate.

Certification basis (G-1) issue papers designate the applicable airworthiness and environmental regulations (noise and environmental findings), including special conditions, that must be met for certification as stated in 14 CFR §§ 21.17, 21.21, 21.25, 21.27, 21.29, or 21.101, as applicable. It also designates applicable Special Federal Aviation Regulations (SFARs), and records any exemptions granted (see 14 CFR § 11.25). This issue paper must provide the definitive justification for selecting the certification basis, including specific amendment levels.
An exemption is a temporary or permanent allowable noncompliance with a particular regulation for a specific product.

Determination of Compliance (G-2) issue papers provide a statement of our procedural requirements, including those that define your responsibilities for showing compliance. This issue paper is designed to capture the “compliance checklist” which shows the regulatory requirement and the method of compliance proposed by the applicant for each regulation identified in the certification basis. For foreign-manufactured products to be eligible for an import type certificate (TC), you must show, and the FAA must find, that the type design complies with the U.S. type certification basis, G-1. Under bilateral agreements, the exporting civil aviation authority (CAA) may be authorized to approve data used for showing compliance to the requirements in the G-1 issue paper. Therefore, the G-2 issue paper outlines the responsibilities of the applicable exporting CAAs.

Environmental Consideration (G-3) issue papers designate the applicable environmental regulations, that is, the regulations establishing standards for aircraft noise and for fuel venting and exhaust emissions for turbine engine powered airplanes.
Note: It is permissible for us to combine the contents of issue papers G-1 thru G-3 into one single master issue paper G-1.

Export (Import) Requirements – Country (G-4). For products exported from the U.S., the G-4 issue paper cites our findings of compliance with the importing country’s airworthiness requirements on the importing CAA’s behalf. For products imported to the U.S., the G-4 issue paper establishes the exporting CAA’s function for airworthiness certification, operating matters, and additional compliance findings relative to those defined in the G-1 issue paper.

New Information. The FAA can use issue papers to examine issues that arise from a better understanding of environmental or other hazards that were not well-understood in the past or that did not exist previously. Such items could include new scientific information on weather threats, such as the quantification of microbursts that occurred in the last 30 years, the substantiation of super cooled liquid droplets environment, cabin ozone hazards, and other potential circumstances where the standards were developed without knowledge of a threat that has been recently identified.

Type Validation. When the FAA is the validating authority (VA), the FAA validation team writes an issue paper for each validation item (VI). A validation item is a certification item or airworthiness standard of particular interest to the validating authority. VIs identify aspects of the design or proposed method of compliance (MoC) that warrant further technical involvement (beyond familiarization) by the VA. VIs are primarily used to define and explain differences between the VA airworthiness standards and interpretations and those of the certificating authority (CA) airworthiness standards. The FAA will also write issue papers on certification basis (G-1) and other unique import requirements.

Other Types of FAA Approvals (Optional). For other FAA approvals (e.g., PMA and 14 CFR § 21.305(d) or § 21.8 (effective 04/16/2011)) The FAA can use issue papers, with discretion, to document and resolve compliance issues where directorate or policy office guidance is required. PMA issue papers document our mutually agreed upon understanding and approach to certification of a part’s design.

Unsafe Features or Characteristics that could preclude certification as defined in 14 CFR § 21.21(b)(2).

All Other Issues during type certification projects that become controversial or may otherwise require type certification board (TCB) action to resolve. An example of this is the nonstandard method/means of compliance proposed by the applicant.

What You Need to Know During the Issue Paper Process.
a. If you are an applicant seeking a TC, STC, PMA, or other type design approval, FAA technical personnel will work closely with you to identify any significant issues that may require a special emphasis for resolution. This step will usually require more detailed technical discussions, correspondence, review of design data and hardware.

b. The FAA encourages you to raise questions or issues that may require extra time or special study for resolution so all significant issues are identified as soon as practicable to allow sufficient time for resolution.

c. Simple documentation of a particular method of compliance that is consistent with existing directives, ACs, or other written FAA policy, or that does not fall into one of the common types of issue papers listed in the previous section, does not require an issue paper.

d. Routine items relative to showing compliance and work relationships would not normally be raised as significant issues unless some special problems are anticipated or develop during the course of the program. Decisions and actions will be documented in correspondence, data submittals, and file records of meetings, conversations, and events. In this regard, it is recognized that what may be routine with an experienced applicant may be treated as a significant issue with an applicant who has limited or no current FAA type certification experience.

e. An Organization Designation Authorization (ODA) holder may not approve issue papers. When necessary, the FAA will develop issue papers as a means of resolving certification issues and the ODA administrator must cooperate with the FAA in this process and provide a company position when requested. The ODA manual establishes the procedures necessary for ODAs to coordinate issue papers. normally any design changes, limitations, or equipment imposed that will facilitate granting the equivalency. An issue paper documents the evolution and conclusion of the request for an ELOS finding.

Note: An ELOS finding and an equivalent safety finding (ESF) have the same meaning.

Proposed Special Condition. The basis for issuing and amending special conditions is found in 14 CFR § 21.16. Under the provisions of § 21.16, a special condition is issued only if the existing applicable airworthiness standards do not contain adequate or appropriate safety standards for an aircraft, aircraft engine, or propeller, because of novel or unusual design features of the product to be type certificated.

The phrase “novel or unusual” applies to design features of the product to be certificated when compared to the applicable airworthiness standards. Special conditions will not be used to upgrade the applicable airworthiness standards when novel or unusual design features are not involved.

Special Conditions Issue Papers must be posted to the Federal Register.

What is the difference between RTCA DO-227 and RTCA DO-311?

RTCA DO-227 contains tests, performance and safety evaluation requirements for non-rechargeable primary cells and batteries containing lithium metal or lithium alloys.

RTCA DO-311 contains tests, performance and safety evaluation requirements for rechargeable lithium battery systems.

If you haven’t found an answer to your question please contact us and we will be happy to assist you.

Test Sample Information

Test   Sample Size
Part I (b) (4): Vertical Test (12 second) 5 pieces: 3″ x 12″
Part I (b) (4): Vertical Test (60 seconds) 5 pieces: 3″ x 12″
Part I (b) (5): Horizontal Test 5 pieces: 4″ x 14″
Part I (b) (6): 45 Degree Test 5 pieces: 10″ x 10″
Part I (b) (7): 60 Degree Test 15 feet
Chapter 18: Airline Blanket Test 1 blanket

Please contact us with any questions regarding samples and sample sizes. The required sample sizes above have some exceptions if the appropriate dimensions are not available.

We select the best samples to be tested from the ones provided by you. Spare samples have been calculated into the amounts above.

Copyright © 2023 McDermed Aviation Consultants. All Rights Reserved. Web Design by iNova